About

Welcome to PSR's Environmental Health Policy
Institute, where we ask questions -- then we ask the experts to
answer them. Join us as physicians, health professionals,
and environmental health experts share their ideas, inspiration, and
analysis about toxic chemicals and environmental health policy.

Achieving Real Chemical Policy Reform

As nurses, we care deeply about the health of our patients, families, and communities. Daily we see children, adults and communities impacted by diseases and conditions such as asthma, cancer, birth defects, infertility, and developmental and learning disabilities. We are alarmed to read a growing body of scientific evidence that links these disorders to chemical exposures. Since its formation, a main initiative of the Alliance of Nurses for Healthy Environments (ANHE) has been to reform the Toxic Substances Control Act of 1976. Reducing exposure to toxic chemicals is a crucial component to addressing the burden of disease faced by so many Americans.

While we commend the bipartisan effort that produced the Chemical Safety Improvement Act and the attention that is being paid to this much needed reform, AHNE is unable to support the bill at this time. AHNE strongly feels that it does not provide many of the health protective measures that need to be addressed in order to have real chemical policy reform. Below are some highlights of our most significant concerns. We urge our Senators to truly support public and environmental health and make changes to the following areas:

Protecting vulnerable populations: Vulnerable populations, including pregnant women and the growing fetus, children, the elderly, and those living in communities with disproportionate environmental exposures, need to be explicitly defined and protected. Science clearly shows that these populations are more biologically susceptible to chemical exposures, which can result in life-long health impacts and higher health care costs.

Preserve states’ rights: In the absence of federal action, states have been enacting legislation to protect the public from toxic chemicals. The Chemical Safety Improvement Act would impede the states’ ability to act on chemicals, even in the absence of federal action, and may preempt longstanding state protections such as California’s Proposition 65 law.

Establish deadlines and timetables: The Chemical Safety Improvement Act lacks clear deadlines for testing and action. History has shown that environmental laws achieve the best results with clear deadlines evident in the legislation.

Ensure adequate data: There must be a minimum amount of data required to evaluate and accurately prioritize chemicals. As the bill is currently written, a chemical may be deemed low priority with only the available data, which is insufficient for the majority of chemicals. Once a chemical is classified as low priority, the US Environmental Protection Agency could not require manufacturers to produce further testing showing that a chemical is a high risk to human health and the environment.

Action on the worst chemicals: One of the most regrettable failures of the Toxic Substances Control Act is that the standard for regulatory action is set so high that it is virtually impossible for chemicals to be phased out of production. This mistake should not be repeated by requiring the EPA to perform an extra level of red tape, once a chemical fails the safety determination, in order for the EPA to phase out a chemical. The EPA would only want to pursue this option for chemicals that are most toxic, and most well studied. The provisions in the Chemical Safety Improvement Act could have the perverse impact of slowing down action on chemicals most clearly in need of regulation.

Right to Know: Nurses and other healthcare providers need access to the identity of chemicals suspected of causing illness and must not be constrained by confidentiality agreements if the public is being harmed by exposure to these chemicals. Without these crucial pieces of information, safe nursing practice is undermined.

The Alliance of Nurses for Healthy Environments looks forward to working with our Senators to strengthen this legislation and put in place regulations that will protect the health of Americans for generations to come.